2025 Universal Registration Document

Name: PubliSpeak
Brand: Ipedis

Social audits⁽¹⁾

Cases of non-compliance identified during social audits of Suppliers by topic⁽²⁾

The Suppliers concerned have been asked to implement action plans for each case of non-compliance listed below. Future audits will verify action plan implementation.

Cases of non-compliance identified during social audits of Suppliers by topic⁽²⁾
Topic	Needs Continuous Improvement	Needs Immediate Action	Zero Tolerance	Total number of non-compilance cases	Relative weighting by topic
Health, safety and the environment	Health, safety and the environment Needs Continuous Improvement 341	Health, safety and the environment Needs Immediate Action 703	Health, safety and the environment Zero Tolerance 11	Health, safety and the environment Total number of non-compilance cases 1055	Health, safety and the environment Relative weighting by topic 41.44%
Working hours	Working hours Needs Continuous Improvement 224	Working hours Needs Immediate Action 321	Working hours Zero Tolerance 0	Working hours Total number of non-compilance cases 545	Working hours Relative weighting by topic 21.41%
Payroll	Payroll Needs Continuous Improvement 142	Payroll Needs Immediate Action 277	Payroll Zero Tolerance 0	Payroll Total number of non-compilance cases 419	Payroll Relative weighting by topic 16.46%
Forced labour	Forced labour Needs Continuous Improvement 31	Forced labour Needs Immediate Action 99	Forced labour Zero Tolerance 9	Forced labour Total number of non-compilance cases 139	Forced labour Relative weighting by topic 5.46%
Sexual harassment and bullying	Sexual harassment and bullying Needs Continuous Improvement 51	Sexual harassment and bullying Needs Immediate Action 43	Sexual harassment and bullying Zero Tolerance 0	Sexual harassment and bullying Total number of non-compilance cases 94	Sexual harassment and bullying Relative weighting by topic 3.69%
Freedom of association⁽¹⁾	Freedom of association ⁽¹⁾ Needs Continuous Improvement 37	Freedom of association ⁽¹⁾ Needs Immediate Action 23	Freedom of association ⁽¹⁾ Zero Tolerance 0	Freedom of association ⁽¹⁾ Total number of non-compilance cases 60	Freedom of association ⁽¹⁾ Relative weighting by topic 2.36%
Standard employment⁽²⁾	Standard employment ⁽²⁾ Needs Continuous Improvement 3	Standard employment ⁽²⁾ Needs Immediate Action 39	Standard employment ⁽²⁾ Zero Tolerance 0	Standard employment ⁽²⁾ Total number of non-compilance cases 42	Standard employment ⁽²⁾ Relative weighting by topic 1.65%
Child labour and young workers	Child labour and young workers Needs Continuous Improvement 16	Child labour and young workers Needs Immediate Action 23	Child labour and young workers Zero Tolerance 1	Child labour and young workers Total number of non-compilance cases 40	Child labour and young workers Relative weighting by topic 1.57%
Disciplinary practices	Disciplinary practices Needs Continuous Improvement 39	Disciplinary practices Needs Immediate Action 0	Disciplinary practices Zero Tolerance 0	Disciplinary practices Total number of non-compilance cases 39	Disciplinary practices Relative weighting by topic 1.53%
Assessment under appropriate conditions⁽²⁾	Assessment under appropriate conditions ⁽²⁾ Needs Continuous Improvement 8	Assessment under appropriate conditions ⁽²⁾ Needs Immediate Action 24	Assessment under appropriate conditions ⁽²⁾ Zero Tolerance 2	Assessment under appropriate conditions ⁽²⁾ Total number of non-compilance cases 34	Assessment under appropriate conditions ⁽²⁾ Relative weighting by topic 1.34%
Subcontracting	Subcontracting Needs Continuous Improvement 20	Subcontracting Needs Immediate Action 13	Subcontracting Zero Tolerance 0	Subcontracting Total number of non-compilance cases 33	Subcontracting Relative weighting by topic 1.30%
Non-discrimination	Non-discrimination Needs Continuous Improvement 24	Non-discrimination Needs Immediate Action 0	Non-discrimination Zero Tolerance 0	Non-discrimination Total number of non-compilance cases 24	Non-discrimination Relative weighting by topic 0.94%
Business ethics⁽²⁾	Business ethics ⁽²⁾ Needs Continuous Improvement 0	Business ethics ⁽²⁾ Needs Immediate Action 22	Business ethics ⁽²⁾ Zero Tolerance 0	Business ethics ⁽²⁾ Total number of non-compilance cases 22	Business ethics ⁽²⁾ Relative weighting by topic 0.86%
TOTAL	TOTAL Needs Continuous Improvement 936	TOTAL Needs Immediate Action 1,587	TOTAL Zero Tolerance 23	TOTAL Total number of non-compilance cases 2,546	TOTAL Relative weighting by topic 100%

Health, safety and the environment: 41.44% of the non-compliance cases concerned the Applicable Rules on Health, Safety and the Environment. Most of these cases concerned the lack of appropriate employee retention measures, of an evaluation plan in the local language, of personal protective equipment and of emergency drills, as well as mishandling of fire extinguishers and protective equipment, failures regarding emergency routes or exits, and the lack of eye rinsing stations.
Working hours: 21.41% of non-compliance cases. Failures to comply concerned the Applicable Rules regarding working hours and mandatory rest periods, but also the lack of documents to ensure appropriate monitoring of these Rules.
Payroll: 16.46% of non-compliance cases. Most non-compliance cases concerned insurance and social security contributions, a lack of documentation for checking compliance with these rules, and a failure to pay the minimum wage, overtime and paid leave.
Forced labour: The non-compliance cases identified for this topic account for 5.46% of all of the cases of non-compliance identified during the social audits performed in 2025. The main remediation measure requested was setting up and amending employment contracts. Other non-compliance cases concerned the lack of a due diligence system to identify or prevent the occurrence of forced labour, the payment of recruitment fees, and the withholding of identity documents.
Sexual harassment and bullying: 3.69% of non-compliance cases. Most of these non-compliance cases concerned the absence of a written policy prohibiting sexual harassment and bullying or relevant processes and training regarding these topics, or the absence of an internal system allowing the situation to be reported without negative consequences for the worker in question.
Freedom of association and right to collective bargaining: 2.36% of non-compliance cases. Most of the non-compliance cases concerned the lack of a policy on freedom of association, the lack of free elections for workers' representatives and management interference in these elections. Elections must be carried out or, in countries where such elections are not legal, worker meetings must be organised or alternative arrangements made for workers to raise any concerns or complaints they may have.
Standard employment: 1.65% of non-compliance cases. Most non-compliance cases concerned the repeated and excessive use of temporary workers or other types of precarious work replacing standard employment.
Child labour and young workers: the non-compliance cases identified for this topic account for 1.57% of all of the cases of non-compliance identified during the social audits performed in 2025. An initial audit revealed the employment of a child under the age of 16. The case concerned a 13-year-old who was involved in manual labour. L'Oréal immediately contacted the supplier, reiterating the importance of prohibiting child labour, particularly in dangerous working conditions. As the company was a prospective supplier, L'Oréal did not begin the commercial relationship.
The other identified cases of non-compliance related in particular to a lack of age-check procedures during the Supplier's hiring processes, as well as failure to respect the applicable legal requirements for employing young workers (such as not organising a pre-employment medical check-up) and apprentices (e.g., failure to respect quotas).
Disciplinary practices: 1.53% of non-compliance cases. Most of the non-compliance cases related to this topic concerned the absence of clear written rules, or illegal rules, unlawful deductions from wages, and/or a lack of communication about the rules to workers.
Assessment under appropriate conditions: 1.34%. These non-compliance cases concerned the lack of documents or their inaccuracy, impacting the proper conduct of the audit.
Subcontracting: 1.30% of non-compliance cases. Most failures to comply related to Suppliers failing to ensure that L'Oréal's standards of ethics are upheld in their own supply chain.
Non-discrimination: 0.94% of non-compliance cases. These non-complaince cases mainly concerned the absence of a clear policy to prevent discrimination in recruitment or discrimination in the payment of wages and other charges. It was also noted that some Suppliers made prospective employees take medicals (to identify pregnancies or certain illnesses) as part of the recruitment process. The Suppliers concerned were contacted to ensure that they amend their policies and processes so that these practices will not recur in the future.
Business ethics: 0.86% of non-compliance cases. Most of the non-compliance cases concerned the absence of a written business ethics or corruption prevention policy, the lack of procedures and training, and the absence of an internal system for whistleblowing and whistleblower protection.

Without prejudice to additional and complementary control measures. In 2025, L’Oréal reported data on L'Oréal and SMETA audits. The two systems do not have the same severity scales. Minor cases of SMETA non-compliance are reported under "Needs Continuous Improvement", major and critical cases under "Needs Immediate Action" and business-critical under "Zero Tolerance".
The table groups together the sections of the L'Oréal questionnaire and the SMETA questionnaire. Equivalences are excluded from this calculation as they inherently constitute third-party validation of the Supplier audit’s compliance status.

2025 Universal Registration Document

3. Risk factors and risk management

Social audits(1)

Cases of non-compliance identified during social audits of Suppliers by topic(2)

Social audits⁽¹⁾

Cases of non-compliance identified during social audits of Suppliers by topic⁽²⁾